Corporate Guarantee Transfer Pricing: TPO Must First Verify International Transaction Status Under Section 92B Before Adjustments

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....HC determined that the Transfer Pricing Officer (TPO) must first evaluate whether a corporate guarantee constitutes an international transaction under Section 92B before proceeding with transfer pricing adjustments. The Tribunal's broad remittance order lacked specificity on this crucial preliminary issue. The HC remanded the matter to the Assessing Officer (AO) with explicit instructions to first determine if the obligation undertaken through the guarantee qualifies as an international transaction. Only upon affirmative determination should subsequent transfer pricing implications be considered. The scope of examination was narrowed to focus specifically on the characterization of the guarantee obligation within the international transaction framework.....